Sorry that this Privacy Statement is long and detailed, but we appreciate and understand the sensitivity of personal genetic information that you entrust to us. This document is intended to fully disclose to you, our user, how we collect, use, disclose and protect your personal information. All of your questions should be answered in this Privacy Statement, but if you have any questions please contact firstname.lastname@example.org
- Athletigen respects your privacy and believes that genetic data should be held to the highest standard of privacy and security.
- Athletigen refers to both US (Health Information Portability and Accountability Act) and Canadian (Personal Information Protection and Electronic Documents Act) legislation in developing our Privacy Statement, policies and practices. We elect to undergo an annual external HIPAA audit to ensure we are in compliance. Athletigen does not sell or distribute individual Personal Information without consent.
- Athletigen provides a secure environment to use the Services.
- This summary provides important information from the full Privacy Statement and it applies to the collection and use of your Personal Information. We suggest you read the whole Statement.
Athletigen means Athletigen Technologies Inc., with its principal place of business based at 1505 Barrington Street, Unit 1207, Halifax, NS, B3J3K5.
Athletigen Research means research and development based on the data obtained from its users. These activities include, among other things, the improvement of services, offering new services and products, and performing data analysis activities that may lead to commercialization with a third party.
Services means Athletigen’s products, services and website (including graphics, text, images and other information displayed on the website) as accessed by users with an account or without one.
What Personal Information We Collect
Personal Information is information that can be used to identify the user either alone or in combination with other information. Athletigen collects the following types of Personal Information (see the Terms of Service for all the definitions):
Registration Information is the personal information you provide when registering and/or purchasing our Services and products.
Genetic Information is information related to your genes generated through the analysis of your saliva by Athletigen or by its contractors, successors, and assignees, or otherwise processed by and/or contributed to Athletigen. Athletigen provides two types of genetic information: your genotype, which is the actual DNA sequence resulting from Athletigen’s analysis, and phenotype, which is the observable trait information resulting from the DNA sequence, such as the sensitivity to caffeine or blood group.
Self-Reported Information is your personal information, including medical conditions, sports-related information, ethnicity, family history, and other information that you enter into the surveys, forms, or features while entering the Athletigen website or using the Athletigen app. .
User Content is all the other information provided by Athletigen users that does not include Genetic Information and Self-Reported Information. This information is distributed publicly or privately, to or through Athletigen.
Web Behavior Information is information on how you users make use of the Athletigen website, which is collected through log files, cookies, and web beacon technology.
Referral Information that you give when referring to Athletigen to your friends and contacts as part of the Athletigen referral program.
How Your Information is Used
Athletigen collects the general personal information you provide to operate your account and to use Athletigen’s services. These include: the provision of our Services; the improvement of our Services and offering new products and services; informing about events; invitations to research projects, obtaining testimonials for promotional purposes; performing quality control checks; conducting other R&D; and conducting Athletigen Research. Your genetic information is used to provide you with the genetic sequencing and the resulting traits relevant to your athletic performance in response to your request to identify your specific training needs.
We use your Registration Information to facilitate your purchases, inform you about the analysis of your Genetic Information, provide you with customer service, manage the Services, and verify your use and visits to our website.
Aggregated Genetic and Self-Reported Information
While genetic information is, in and of itself, interesting, its use and value increase when you are able to compare it to the genetic and other information of other people. The only way that scientists have been able to understand the effects of certain genetic traits is by comparing a sample to another population. Athletigen is building on knowledge derived in this way and we intend to participate in building even more knowledge. Users take advantage of this and also participate in this.
We may disclose to third parties “Aggregated Genetic and Self-Reported Information”, which is information that has been obtained from your Registration, Genetic, and Self-Reported Information, and aggregated with the data of other users to minimize the exposure of individual information while still providing enough scientific evidence. We also de-identify this data by removing any information that is directly related to you, such as name, address, and email. We will take reasonable measures to make this information non-identifiable, meaning that it would not be reasonably foreseeable that the information could be utilized, either alone or with other information readily available, to identify an individual or to connect an individual to any particular data. We will also make efforts to only provide the minimum amount of Aggregate Genetic and Self-Reported data that is necessary to answer research questions. We will also use contractual means to protect the privacy and security of your Aggregated Genetic and Self-Reported Information when we work with research partners
The goal of these research partnerships is to accelerate discovery, and may lead to scientific publications, intellectual property creation, and/or commercial applications, which users will not be credited for nor receive any financial benefit from.
Except for de-identified and/or anonymized information as described in this section, we will never release your Genetic and/or Self-Reported Information to a third party without asking and getting explicit consent from you to do so, unless we are required to by law. If we are legally required to disclose such information, we will make reasonable efforts to notify you unless we are legally prohibited from doing so.
Web Behaviour Information
We use Web Behaviour Information to understand how users make use of our website, for R&D purposes, for quality control in order to improve our Services, and to advertise products and services. This information will not be shared with any third parties without consent, except following de-identification by anonymization and aggregation.
- We will not disclose your personal information to any third party except with your informed and express consent or as required by law, upon verified lawful authority as explained in section 9.
- Where we transfer your personal information for processing, it will be exclusively with contractual and other means to ensure a comparable level of protection and to carefully screened partners or ether service providers, such as the contracted laboratory that collects and analyzes your information in order for you to use Athletigen Services.
- Where we provide information to research and research contractors in the form of de-identified, aggregate information, for scientific research purposes we screen these research contractors and we subject them to the rules established by Athletigen.
- Aggregate, de-identified data may lead to commercial use.
Information Disclosure as Required By Law
Under some circumstances, Personal Information other than Genetic Information, can be shared pursuant to judicial or other government orders, or in coordination with regulatory authorities. You understand and accept that Athletigen is free to keep and disclose Personal Information to law enforcement agencies, as required by law, or in the good faith that such disclosure is necessary to: (a) comply with legal or regulatory processes or obligations that Athletigen might owe to ethical or professional rules, laws, and regulations; (b) enforce the Athletigen TOS; (c) respond to claims that any content is violating the rights of third parties; or (d) protect the rights, property or Athletigen’s safety and the public. If we are required by law to make a disclosure, we will notify you through the contact information that you have provided us, unless doing so can violates the law or a court order.
Providing your Personal Information other than Registration Information is voluntary and based only on the permission you give.
Sharing Self-Reported Information through surveys, wearable integrations, or other website features, is voluntary.
If you provide a written request, we will close your account. All Genetic Information will accordingly be deleted from your account and no one will be able to access it. Athletigen will not use your Genetic Information in new scientific research that starts thirty (30) days or more after your account is closed. We cannot delete Genetic Information that has already been used for scientific research or that has been shared with external collaborators before the account is closed. (See “Account Closure and Correction of Personal Information”).
Athletigen is committed to keep the trust you place in us. To prevent prohibited access or disclosure, to maintain information accuracy, and to ensure using the information appropriately, Athletigen uses various physical, technical, and administrative measures to keep your Personal Information, as it is stated in current standards. Particularly, all connections to our website and our mobile applications are encrypted using Secure Socket Layer (SSL) technology. All our production machines (including databases) are behind VPC and can only be accessed via a secure VPN network . For added security, our database cluster is inside a private subnet (within the VPC) making it impossible to perform any brute force attack on the machines directly.
Please understand that protecting your Personal Information is also your responsibility. We ask for you to be responsible for keeping your password secure, as well as other authentication information that you use to access the Services. You should not share your authentication information to any third parties and you should inform Athletigen immediately of any prohibited use of your password. Athletigen cannot keep the Personal Information that you release or that you request us to release safe.
In the event that Athletigen or a business unit of Athletigen is bought, sold, transferred, spun-out or merged with another entity, your Personal Information will be transferred along with the other assets. In this case, your information would remain subject to the terms of this Privacy Statement.
Privacy Statement Changes
This Privacy Statement was updated on August 25, 2014. When any significant change is made to the Privacy Statement, a notice will be posted as part of this Privacy Statement and it will be placed on our homepage for 30 days. After 30 days, the changes will become effective. Additionally, all of our customers will receive an email notifying them that changes have been made.
If you continue to use the service after the effective date of the change, you will be considered to have agreed to the amended Privacy Statement. If you do not agree to the amended Privacy Statement, you have the option of ending your Athletigen account by contacting us at email@example.com.
Closing an Account and Correcting Personal Information
If you do not want to participate any longer in our Services, you can close your account by sending a request to Customer Care at firstname.lastname@example.org. When you close an account, we remove all of your Genetic Information within thirty (30) days of when we receive your removal request. However, Genetic Information and/or Self-Reported information will not be removed from ongoing or completed studies that use this information. Our contracted laboratory may also retain your de-identified Genetic Information as required by law. Additionally, we keep Registration Information as it is related to your order history for accounting purposes.
If there are any changes in your Personal Information, you can correct or update them by accessing your Account Settings page. You can also correct or reset Self-Reported Information entered into the surveys from within your account.
How to File a Complaint
You have the right to file a complaint if you do not agree with how we have used or disclosed your Genetic, Self-Reported, or Registration information. All complaints must be submitted in writing. Your services will not be affected by any complaints you make. We cannot retaliate against you for filing a complaint or refusing to agree to something that you believe to be unlawful. Please contact our Privacy Officer below, who will attempt to expeditiously resolve any concern or complaint you may have. Alternatively, you can contact a data and privacy protection organization for assistance or advice.
How to Contact Us
Questions regarding this Summary, the Privacy Statement, or how Athletigen handles your Personal Information can be emailed to email@example.com or mailed to:
Athletigen Technologies, Inc.
1207-1505 Barrington St.
Halifax, NS B3J 3K5